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LOTTO NETWORK PRIVACY POLICY

This Privacy Policy was last modified on 22 May 2018

General

The purpose of this document (the "Privacy Policy") is to let you know what kinds of information Luton Town Lotto, (operated by Lotto Network Limited, "we", "our" or "us") may gather about you as a result of your use of the Luton Town Lotto website (the "Web Site"), how we may use that information, whether we disclose it to anyone, and the choices you have regarding our use of the information.

The Web Site is operated by Lotto Network. Lotto Network, acting as a betting intermediary, places a Player's bets with MyLotto24, which acts as bookmaker for the Player. In placing bets, Lotto Network acts as agent on behalf of, and on the instructions of, the Player. Lotto Network is responsible for operating the Web Site, establishing and operating Player Accounts, placing of Players' bets with MyLotto24, delivering Stakes waged by Players to MyLotto24, and passing on to Players the Prizes/Winnings received from MyLotto24, in accordance with these Terms.

The Club is not a party to these Terms.

These Terms (including the Privacy Policy) may be changed at any time. Lotto Network Limited will ensure that any new or revised version is posted on the Web Site and will send notification of any changes to the registered email address held on the Player Account before the change takes effect. The new or revised version of the Terms will take effect immediately on the Player's next use of the Luton Town Lotto Services.

Processing of personal data

We process various personal data within the framework of the organization and promotion of our lottery. Below we describe the various processing operations, in which we indicate the basis and for which purpose(s) we process personal data.

Registering for Luton Town Lotto account

You can register a Luton Town Lotto account with us. This is your own unique account that is protected with a password of your choice. With this you can easily log in from your PC, tablet or mobile to your personal environment, manage your own environment, buy tickets and find extra information about our services and products. When you register a Luton Town Lotto account, we request information from you to create your Luton Town Lotto account and enable you to use the account.

The legal basis is the implementation of the agreement

You must provide the following information:

First and Last name

Date of Birth

Address

Email

Password

Telephone

The data mentioned at the 2 you may not change in principle. The data at 1, 3, 4, 5, and 6 you can always change in your Luton Town Lotto account.

You are responsible for a correct registration. We are authorised to verify the accuracy of the information you provide. The information provided is checked for correctness on the basis of available data files.

Minors

You may only participate in placing bets with
Luton Town Lotto
if you are 18 or older.
When you sign up to an account, you are therefore investigated on the
basis of the data and information from public sources provided by you
when registering
Luton Town Lotto
account or we can confirm
that you are 18 years or older. To do this we use Experian. For more
information about Experian follow this link
https://www.experian.co.uk/

The lawful processing ground is compliance with a legal obligation. Namely, Social responsibility code provision 3.2.11, Number 1 (Access to gambling by children and young persons - remote SR code) of our LCCPs.

In the event that we cannot confirm your age, you are given 72 hours to provide proof of age. After this timeframe, you cannot participate in games offered by Luton Town Lotto.

Placing Bets

You can only place bets when you have registered a Luton Town Lotto account with us. This can be done via the Luton Town Lotto site. You can participate once or take out a subscription so that you never miss a draw.

In the context of buying tickets, we process the following data from you to process orders:

First and Last name

Date of Birth

Email Address(and username)

Payment details

The lawful processing ground is for this is that this is necessary for the implementation of the agreement.

The data under 1 to 3 we obtain when you register your Luton Town Lotto Account. The data under 4 we obtain because you make a payment.

Use Luton Town Lotto account

We also process data in the context of the use of your Luton Town Lotto account.

(a) Data analysis and the development of our products and services

It is important to us that our online environment works well so that we can offer our products and services. We therefore use gaming data and data relating to your gaming behaviour for data analysis and the development of our products and services. In this way we can identify and adjust errors or improvement points in our products and services.

The legal basis is the legitimate interest we have in being able to offer our products and services through a well-functioning environment.

It concerns the following data:

Play data such as your session number;

Information regarding your gaming behaviour such as the time and
duration of the Internet sessions, data about pages visited and data
relating to prizes, participations or subscriptions.

The data mentioned under 1 and 2. we obtain because you participate in placing bets on the Luton Town Lotto Site

(b)Playing Limits

In addition, we use your data and any limits you specify for the purposes of consumer protection.

Information regarding your gaming behaviour such as the time and duration of the Internet sessions, data about pages visited and data relating to prizes, participations or subscriptions.

The data under 1 and 2 we obtain when registering your Luton Town Lotto account. The data mentioned under 3 and 4. we obtain because you participate on the Luton Town Lotto site and place bets through the Luton Town Lotto site.

Emails for which you cannot unsubscribe yourself

First of all, we process data in connection with sending e-mails for which you cannot unsubscribe yourself.

The legal basis is the execution of the agreement. This concerns the
following types of emails:

when you have won a prize;

about transactions made by you;

about changes to your player account, including the confirmation email when registering.

In addition, we can send you an e-mail on your
Luton Town Lotto
account in case of inactivity to ask if you would like to continue using
your account. The legal basis is then the legitimate interest we have
in checking whether you still want to use your
Luton Town Lotto account.

For the above e-mails we use the following data:

First and last name (all e-mails);

Telephone number (when you have won a prize);

E-mail address (all e-mails);

Play data such as your player number (all e-mails);

Information regarding your gaming behaviour such as the time and duration of the internet sessions, data about pages visited and data relating to prizes, participations or subscriptions (when you have won a prize, about transactions you have made and in case of inactivity on your Luton Town Lotto account);

Payment details such as your bank account number, balance and play credit (when you have won a prize and transactions you have made).

The data mentioned under 1 to 3 we obtain because you specified this
when registering your
Luton Town Lotto account. The data mentioned under 4 and 5 we obtain
because you participate on the
Luton Town Lotto site. The data mentioned under 6 we obtain because you
place bets through the
Luton Town Lotto site.

Emails for which you can unsubscribe yourself

In addition, there are e-mails that we can send to you if you have registered for it and for which you can unsubscribe. It concerns the e-mails with which we inform you about:

The legal basis is consent. You can always revoke this permission in your account settings or by clicking on the unsubscribe link in the email.

For these mails we use the following data:

First and last name;

E-mail address;

Play data such as your player number

Information regarding your gaming behaviour such as the time and duration of the Internet sessions, data about pages visited and data relating to prizes, participations or subscriptions.

The data in 1 to 2 we obtain because you specified this when you registered you Luton Town Lotto account. The data under 3 and 4 we obtain because you participate on the Luton Town Lotto site and place bets on the Luton Town Lotto site.

Payment of Prizes

We use a strict validation process when designating the winning participants.Â
Therefore, in case you win a prize, we will check your identity. We can
do this by checking the data entered at registration for accuracy, for example by testing against information from public sources.

Information regarding your gaming behaviour such as the time and duration of the Internet sessions, data about pages visited and data relating to prizes, participations or subscriptions.

Payment details

For the data mentioned under 1 to 3 we obtain this because you specified this when registering your Luton Town Lotto account. The data under 4 we obtain because you Participate on the Luton Town Lotto site. The data under 5 we process because you Participate in placing bets on the Luton Town Lotto site .

If you win a prize, we can also ask you to provide documentation, for example, but not limited to, a copy of a valid proof of identity, on which you must make your citizen service number and passport photo unreadable, and / or proof of (registration on a determined) address. We will destroy this information after we have verified your identity.

In case of a win €2,000 or above the following procedure is followed
. The Player must contact Customer Services. The Player will be asked to provide a copy of their ID and a bank statement. Then the Luton Town Lotto Payments, Fraud and Verification Team will then carry out the necessary due diligence. Once the due diligence is carried out, they payment will be made. The data will then be destroyed unless there is a lawful reason/requirement for retaining the data.

If you refuse to cooperate in establishing your identity, we can choose not to pay your prize.

Deleting your Account

You can delete your Luton Town Lotto account via the following methods:

Players may close their Player Account by giving us at least 24 hours' notice (by e-mail to customer service at service@lutontownlotto.com once their Player Account has a zero balance and all draws on which Bets have been placed, have already taken place.

If you do so, we are required to retain your personal information for a period of five years. The lawful processing ground is compliance with legal obligation. Namely, the Money Laundering Regulations 2017, Part 4, Section 40(3) and Part 2, Section 21(8).

First and last name;

E-mail address;

Play data such as your player number;

Information regarding your gaming behaviour such as the time and duration of the Internet sessions, data about pages visited and data relating to prizes, participations or subscriptions.

Payment details

Customer Service

It is important to us that you have a pleasant experience with our
products and services. We therefore have a customer service, where you
can include your questions. Our customer service is available via
telephone, e-mail and post. If you contact our customer service, we will
use your details. We use this information to handle your requests and
to improve our services. If you have a
Luton Town Lotto account, we can store this personal data with your other
customer data. This is useful if you call us again and it gives us the
opportunity to improve our services.

The legal basis is the implementation of the agreement.

We use at least:

First and last name;

Telephone number, e-mail address or address (depending on how you reach us);

Play data such as your player number.

Depending on your question, we also use:

Information regarding your gaming behaviour such as the time and duration of the Internet sessions, data about pages visited and data relating to prizes, participations or subscriptions;

Payment details such as your bank account number, balance and play credit;

Other information that you provide to us during contact with customer service.

The data mentioned under 1 through 3 we obtain because you specified
this when registering your
Luton Town Lotto account. The data mentioned under 4 we obtain because you
participate on the
Luton Town Lotto site. The data mentioned under 5 we obtain because you
Participated in placing a bet on the
Luton Town Lotto site. You can also provide the information to us by or
during the contact with our customer service.

Verification of Identity

Upon customer registration, we conduct Experian validation checks. This includes the following types of data:

First name and last name

Date of birth

Address

We also conduct a check against lists of Politically Exposed Persons and Sanctions. Should a customer fail the Experian checks, we request proof ID and all data is checked and validated with account details. Enhanced due diligence checks are carried out during daily fraud and monitoring tasks i.e. New registrations and daily pay-outs. Additionally, we have set a report for a pay-in threshold above 70.00 GBP. At this point we carry out further due diligence checks

Suspicious activities

It is possible that suspicious activities occur on your
Luton Town Lotto account, such as unusual gaming behaviour or acting in
violation of our rules, conditions or our policy. With a view to
preventing fraud or abuse of your
Luton Town Lotto account, we consider it important to verify your
identity.

The legal basis is the legitimate interest we have in preventing fraud and abuse of Luton Town Lotto accounts.

In case of suspicious activities as described above, we can ask you to
send us a copy of your identification document, on which you make your
citizen service number and passport photo unreadable, to determine your
identity. You can also state on the copy that it is a copy and for what
reason you send the proof of identity to us (for example: "Copy for preventing fraud").

If you refuse to cooperate in establishing your identity, we can take measures such as blocking or even deleting your Luton Town Lotto account.

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data

Request correction of your personal data

Request erasure of your personal data

Object to processing of your personal data

Request restriction of processing your personal data

Request transfer of your personal data

Right to withdraw consent

If you wish to exercise any of these rights, please contact customer services.

We respond as quickly as possible to your requests and objections, but at the latest within four weeks.

Retention periods

We do not store your personal data for longer than necessary for the
purpose / purposes for which they were collected or processed. In some
cases, we will have to keep your personal data in order to comply with
our statutory legal obligations. Namely, anti-money laundering legislation.

Security

We have taken appropriate technical and organizational measures to protect your personal data against loss or against any form of unlawful processing.

Provision to third parties, within a group and transfer to countries outside the EU

(a)Provision to third parties

During the execution of our activities we use services from third parties (such as: call centres, advertising agencies, printing companies, research agencies, etc., but also our group members).Â It is possible that these parties process your personal data for us.Â They do this in the capacity of processor / processor for us and we ensure that these third parties only process personal data in accordance with this Privacy Policy and the applicable laws and regulations.Â We do this, among other things, by making suitable contractual guarantees.

Only if we are required to do so by law, personal data will be provided to supervisors, tax authorities and investigative authorities, for example if a request from the police comes in the event of fraud or illegal activities.

(b)Transfer to countries outside the EU

We or third parties engaged by us will only store or process personal data outside the European Economic Area (EEA) if this is in accordance with the applicable regulations for the transfer of personal data to countries outside the EEA.

Cookies

The Web Site uses cookies to deliver a better and more personalised service to Players. This section explains what cookies are, how they are used on the Web Site and how to manage their use.

What is a Cookie?

Cookies are small text files containing small amounts of information which are sent to and stored on your computer, smartphone or other device when you access a website. Cookies are generally used to improve and enhance the user experience.

Use of Cookies on the Web Site

Cookies may be used on the Web Site for a number of reasons. This includes, but is not limited to, the following:

to allow Players to choose and maintain their account preferences;

to monitor and collect information about transactions placed on the Web Site;

to monitor the number of visitors to our Web Site and see how visitors move around the Web Site; and

for fraud prevention purposes and to generally safeguard privacy.

A list of the cookies that we use and their function is below:

Cookie

Lifetime

Purpose

Session-ID

Session

When connecting with our server, your device will be allocated a remote number ("session-ID"), which enables our server to identify your device during the session. The session-ID facilitates usability of the website, will be deleted automatically upon termination of the browser, and will not be submitted to third parties.

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Varies - session to as long as the browser/user allows.

Google Analytics tracking cookie (www.google.com/analytics/). These cookies give us information on how users move around the website. We use the data to see what is popular on the site and not, which enables us to work to improve the site. The data cannot be used to identify you and we will not share the data with third parties.

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cookieNotice

1 Year

This cookie tells us if you have accepted our cookie policy.

In certain cases, the Web Site may also employ flash cookies. Flash cookies are used to improve and enhance your web browsing experience (such as enabling advertising to be specifically tailored to your interests or facilitating purchases to be transferred to your shopping basket when making a purchase). For further details about flash cookies, please visit: kb2.adobe.com/cps/526/52697ee8.html. To adjust your preferences for Flash cookies (and whether or not you wish to accept them for the Web Site or other websites), please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

You may delete and block all cookies from the Web Site, but parts of the Web Site may not then work. Most web browsers allow some control of most cookies through the browser settings, for example you can set up your web browser to inform you when you receive a cookie, giving you the chance to decide whether or not to accept it. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit tools.google.com/dlpage/gaoptout.

Changes to Privacy Policy

We reserve the right to change this Privacy Policy. We will always
inform you of changes to this Privacy Policy, so that you can determine
yourself whether you agree. The date of the most recent version is
mentioned above.